Over 18 months ago the Coalition sounded the call to arms against what we are now calling "MicroGoo".  So we welcome NAB and others into this existential fight for the spectrum we all will need to repack into.   And we trust NAB is ready to go to court over this issue, as it could dramatically impact the entire industry.  The key point that MicroGoo seems to forget is that they are being given already in the repack 18-24 MHz of "free" spectrum with the guard bands.  And the fact that TV white space devices can operate already in the TV band, well we will see just how hard the FCC wants to push this issue.  Can they really afford yet another 3-6 month trip to the Courts?  Does MicroGooApple intend on paying all of those off shore taxes they are ripping up all off with?  Pay for the damn spectrum you want MicroGooApp, and stopping being so unAmerican!  Pay your damn corporate taxes!!!!!!!!  The value of 3 channels nationwide for unlicensed use is worth over $18 Billion in lost auction revenues!!!


The Coalition was first to point out in the record that the FCC could not identify the "100 auction ineligible" Class-A's which were mentioned in the original incentive auction NPRM.  This list was finally whittled down to just four (4) Class-A's which would not be eligible for the auction, despite being Class-A's, and operating under those rules since before the auction legislation was passed. We have even filed into the record in support of their cause.  Will these four licensees now go to court?  Will they try to stop the auction so that they are included?  Heck, combined, they could be looking at over $100 million in opening bids, so yes, they probably will do some legal action - and we will let you know as soon as we find out.

There is a lot of talk about a "regional repacking" scheme, which is being pushed by some industry consultants.  Well, unless these regional repacks also include LPTV and translators, there is no way we are going to be forced to wait to build out.  Question:  Is a "market" cleared from 51-38 if all of the primaries and Class A's have repacked?  Just what is the 39 month period all about?  Isn't it just the time to apply for relo funds, and not a "guaranteed" amount of time to stay on channel before you have to move?  We need to expect the winning bidders to try to get us off "their" spectrum as fast as possible.

So, if 24% of all households do NOT have cable or satellite, does that not mean that OTA could have as high as 24% "exclusive" coverage nationwide?  Hmmm, seems like CES/CTA and others need to re-evaluate their own research, which says 7-10% OTA.

Mike Gravino
LPTV Spectrum Rights Coalition
(202) 604-0747